Real estate market is also pretty tough to beat!

It appears beating the market in a risk adjusted basis may be almost as difficult in Real Estate as it is in the financial markets.

Penn State Live - Study: Only select group of property fund managers outperform market:

"...'Maintaining consistently high levels of alpha is incredibly difficult for most fund managers to achieve, however, one feature that we did note is that mangers using a value strategy appeared better placed to deliver high alpha in subsequent periods.'

Mitchell adds: 'Doing things differently from, instead of better than, your peers seems to be the key. It will be interesting to see how the 'beta' investors' strategies evolve in a world where market exposure can potentially be attained cheaply through property derivatives.'

While the researchers examined property funds in the U.K., Bond says he would expect the results to be similar in the United States."

The full paper is available here.